Published on 17 Nov 05
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This paper covers:
- the distinction between debt and equity
- comments on the US, UK and Canadian experience
- current issues:
- effect of solvency clauses for project finance, lower tier 2 capital
- what if you cannot institute winding-up proceedings on a default by a company?
- the effect of conversion rights and options, including TD 2004/D76
- the ambit of section 974-80.
Martin Fry, FTI, is the Practice Leader of the Allens Tax Group. With over 20 years as a Partner of Allens, Martin advises corporations on a broad range of tax issues across a wide range of sectors, including resources, infrastructure, financial services and IP-intensive businesses. In recent years, Martin has focused on contentious transfer pricing matters, including audits, settlement negotiations, mutual agreement procedure and litigation. Martin has taught Corporate Tax at a postgraduate level at the University of Melbourne.
- Current at
12 May 2021
Brad, a Senior Associate with Allens Arthur Robinson, practices in international and corporate taxation. He has experience in a wide range of income tax matters including sales, acquisitions and restructures, financing arrangements, and advising companies on the impact of tax consolidation in M&A transactions.
Current at 23 July 2004